Tim Lors v. Jim Dean, 726 F.3d 1036

Lors alleges retaliation by BIT and state employees for his prior discrimination suit, asserting federal-court jurisdiction under ADA Titles I and V and other civil rights statutes.
BIT and employees moved for summary judgment on merits; district court granted, and this court later sua sponte ordered supplemental briefing on sovereign immunity.
Lors previously sued for discrimination under Rehabilitation Act/ADA; CSC found no retaliation; unemployment benefits denial followed.
Plaintiff sought money damages and may have requested injunctive relief, but no explicit prospective injunctive relief pleading was found.
Court holds sovereign immunity bars money-damages claims under Titles I and V of the ADA; lack of pleaded prospective injunctive relief defeats jurisdiction on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sovereign immunity bars ADA claims for money damages	Lors argues Title I/Title V claims survive despite immunity	BIT and employees contend Eleventh Amendment bars monetary relief	Yes, money damages barred by sovereign immunity

Alsbrook v. City of Maumelle, 184 F.3d 999 (Eighth Cir. 1999) (Title II extension to states not proper abrogation of Eleventh Amendment immunity)
Doe v. Nebraska, 345 F.3d 593 (Eighth Cir. 2003) (extension of Title II not valid abrogation; no subject-matter jurisdiction over ADA claim against state)
Garrett v. University of Alabama, 531 U.S. 356 (Supreme Court 2001) (Title I ADA claims against states barred by Eleventh Amendment unless state waives immunity)
Faibisch v. Univ. of Minn., 304 F.3d 797 (Eighth Cir. 2002) (state immunity from Title I ADA claims unless waived)
Demshki v. Monteith, 255 F.3d 986 (Ninth Cir. 2001) (Title V claims predicated on Title I barred by sovereign immunity; reliance on Garrett)